Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Reopening of assessment u/s 147 - Capital gain on sale of property - there is “reason to believe” the income chargeable to tax has been under assessed, in view of certain sale transactions, which all are not recognizable under the provisions of the relevant Statutes. Thus, the petitioner is bound to participate in the reassessment proceedings by availing the opportunities to be provided by the competent authorities and established his case in the manner known to law. Writ petition fails. - HC
Reopening of assessment u/s 147 - Capital gain on sale of property - there is “reason to believe” the income chargeable to tax has been under assessed, in view of certain sale transactions, which all are not recognizable under the provisions of the relevant Statutes. Thus, the petitioner is bound to participate in the reassessment proceedings by availing the opportunities to be provided by the competent authorities and established his case in the manner known to law. Writ petition fails. - HC
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